CMS Medical Credentialing Policy Changes (2026): A Complete, CMS-Sourced Guideline for Providers & Billing Teams

Medicare enrollment and provider credentialing are at the beginning of the revenue cycle. Claims will be delayed if an enrollment record is inaccurate, incomplete or not reported for a required deadline. CMS has issued several credentialing- and enrollment-related updates that took effect or were clarified in 2026.

Major CMS Credentialing & Enrollment Changes in 2026

For 2026, CMS has made a number of Medicare enrollment and credentialing changes that healthcare providers, suppliers and billing teams should be aware of. These modifications aim to increase program integrity, increase proper enrollment numbers, and allow only qualified providers to participate in Medicare. 

These policy changes can have a direct impact on Medicare participation, compliance and reimbursements, from updated enrollment application fees to specific enrollment requirements for physicians who only order or certify Medicare services. By staying informed and adhering to CMS guidelines, providers can minimize the chances of claim denials due to credentialing problems, ensure uninterrupted Medicare coverage, and avoid enrollment delays. 

2026 Medicare Enrollment Application Fee

CMS has mandated a $750 fee for certain healthcare organizations and suppliers to submit Medicare enrollment application transactions beginning in 2026. This fee is for institutional providers and certain types of providers (such as Durable Medical Equipment, Prosthetics, Orthotics and Supplies (DMEPOS) suppliers and opioid treatment programs (OTPs).

The application fee is required when a provider or supplier:

• Enrolls in Medicare for the first time
• Re-enrolls after leaving the program
• Completes a Medicare revalidation
• Adds a new practice location to an existing enrollment

Providers submitting their enrollment electronically can pay the fee directly through the Provider Enrollment, Chain, and Ownership System (PECOS) during the application process. Those filing a paper application may submit payment separately through the PECOS Application Fee Information portal. CMS also provides a hardship exception for eligible applicants who qualify for an exemption from the current application’s fee.

Enrollment Requirements for Providers Who Only Order or Certify Medicare Services

Not all healthcare professionals are directly billed to Medicare. Medicare-enrollable physicians and other practitioners who only order or certify Medicare covered services are still required to comply with Medicare enrollment requirements.

If a provider only orders or certifies Medicare services, and does not submit billed-service claims to a Medicare Administrative Contractor (MAC), they must either:

• Enroll in Medicare using Form CMS-855O, or
• Have a valid Medicare opt-out affidavit on file.

This enrollment pathway is separate from the standard Medicare billing enrollment. It is a common credentialing gap for referring and ordering physicians who assume that Medicare enrollment is unnecessary because they do not bill the program directly. Failing to complete the appropriate enrollment can create compliance issues and may affect Medicare payment for services ordered or certified for beneficiaries.

How Often You Need to Revalidate Your Enrollment?

A quick reference for how often different enrollment types are revalidated under standard CMS cycles, plus where to verify a specific provider’s due date.

Provider/Supplier Type	Standard Revalidation Cycle	Where to Confirm
Most Medicare providers & suppliers	Every 5 years	CMS Medicare Revalidation List (via PECOS)
DMEPOS suppliers	Every 3 years	CMS Medicare Revalidation List (via PECOS)
SNFs (off-cycle ownership/related-party reporting)	Off-cycle, as requested – Jan 1, 2026 deadline currently suspended	CMS Provider Enrollment and Certification page

How does CMS approve or Deny Medicare Enrollment Applications?

For providers, practice administrators, and credentialing teams, understanding these review standards is essential because CMS continues to apply them when evaluating enrollment eligibility.

What Counts as an Affiliation?

CMS broadly defines an affiliation as a relationship between a provider or supplier and another individual or organization that demonstrates a significant ownership or management interest. An affiliation may include:

• Direct or indirect ownership of 5% or more
• A general or limited partnership interest
• Exercising operational or managerial control over an organization
• Serving as a board member or in another position with management authority

These relationships may be reviewed during the Medicare enrollment process if CMS requests affiliation information.

When Can CMS Deny or Revoke Enrollment?

CMS may deny a new enrollment application or revoke an existing Medicare enrollment if an affiliated provider or supplier poses a program integrity risk. Examples include affiliations with organizations or individuals that have:

• An active Medicare or Medicaid payment suspension
• A revoked or suspended professional license in another state
• Been terminated from a federal healthcare program

CMS evaluates these affiliations to determine whether they create an undue risk of fraud, waste, or abuse within the Medicare program before approving or maintaining enrollment.

Reporting Enrollment Changes Remains a Compliance Requirement

Enrolled providers and suppliers are also responsible for keeping their Medicare enrollment information current. Certain changes, such as ownership updates or final adverse legal actions- must be reported to CMS within the required timeframe.

In most cases, CMS will look for a report within 30 or 90 days, depending on the provider/supplier type and nature of the change. Failure to meet these deadlines could cause compliance problems and could impact a Medicare enrollment. 

Affiliation Disclosures Are Requested Through PECOS

CMS follows a phased implementation approach for affiliation disclosures. Rather than requiring every provider to report affiliations during every enrollment transaction, CMS requests this information only when specifically instructed as part of the Medicare enrollment process.

If necessary, providers provide affiliation information by updating their Form CMS-855 affiliation applications on the Provider Enrollment, Chain, and Ownership System (PECOS). To prevent unwarranted enrollment delays or further review, credentialing teams must review CMS requests with great care and complete and accurate all disclosures. 

Major CMS Credentialing & Enrollment Changes

The most significant changes include an updated Medicare enrollment application fee for eligible providers and suppliers, new accreditation requirements for DMEPOS suppliers, and important developments regarding CMS-approved accreditation organizations.

Updated Medicare Enrollment Application Fee

CMS has determined that the Medicare enrollment application fee for calendar year 2026 is $750. Not all Medicare beneficiaries will have to pay the fee, depending on the type of provider and the type of Medicare supplier. 

The application fee is required for:

• Institutional providers
• Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers
• Opioid Treatment Programs (OTPs)
• Other provider or supplier types that CMS identifies as subject to the application fee

The fee must be paid when an organization:

• Enrolls in Medicare for the first time
• Re-enrolls in the Medicare program
• Completes a required Medicare revalidation
• Adds a new practice location to an existing Medicare enrollment

Providers who are applying electronically will be allowed to pay the fee during the enrollment process via the Provider Enrollment, Chain, and Ownership System (PECOS). Those who are completing their application on paper can pay the application fee separately from the PECOS Application Fee Information portal. 

CMS also offers a hardship exception for eligible applicants who qualify for an exemption from the current application’s fee.

Individual physicians, non-physician practitioners (NPPs), physician organizations, non-physician organizations, and Medicare Diabetes Prevention Program (MDPP) suppliers are generally exempt from the Medicare enrollment application fee unless CMS specifically requires otherwise.

New Accreditation Rules for DMEPOS Suppliers

CMS finalized new accreditation provisions for Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) suppliers as part of the Calendar Year (CY) 2026 Home Health Prospective Payment System (HH PPS) Final Rule.

The new accreditation standards are designed to help improve CMS oversight of DMEPOS suppliers, fix weaknesses in the accreditation process and enhance the quality requirements for Medicare suppliers.

It is a fundamental necessity for DMEPOS suppliers to maintain accreditation through a CMS approved accreditation organisation in order to be enrolled in Medicare and continue to participate in the program. Suppliers should review and adhere to the latest accreditation requirements and be closely working with their accreditors to meet requirements.

BOC Accreditation Status Update

Credentialing teams should also be aware of an important accreditation-related development involving the Board of Certification/Accreditation International, Inc. (BOC).

CMS withdrew BOC’s approval as a CMS-recognized DMEPOS accreditation organization on December 2, 2025. However, BOC challenged the decision in the U.S. District Court for the District of Maryland.

On January 9, 2026, the court issued a Temporary Restraining Order (TRO) that temporarily stayed CMS’s withdrawal decision. As a result, BOC continues to remain a CMS-approved DMEPOS accreditation organization until further notice.

Suppliers of DMEPOS who are accredited by BOC should keep an eye on CMS announcements and any future court rulings, because any decision by BOC to revoke its accreditation or change its Medicare enrollment status may impact the accreditation and Medicare enrollment status of those suppliers. 

CMS Credentialing Compliance Checklist for 2026

Use this checklist to help ensure your Medicare enrollment records remain accurate, compliant, and ready for CMS review.

• Verify that your PECOS enrollment record matches your NPPES information exactly. Inconsistent provider information between these systems can lead to Medicare claim rejections or processing delays.
• Confirm that physicians and eligible professionals who only order or certify Medicare services are properly enrolled. Providers who do not bill Medicare directly should either be enrolled using Form CMS-855O or have a valid Medicare opt-out affidavit on file.
• If your DMEPOS organization is accredited through the Board of Certification/Accreditation International, Inc. (BOC), monitor CMS announcements regularly. BOC currently remains a CMS-approved accreditation organization under a court-issued Temporary Restraining Order (TRO), and its status may change based on future CMS actions or court decisions.
• Skilled Nursing Facilities (SNFs) are permitted to continue to maintain ownership, managerial, and related-party information.
• Plan for the 2026 Medicare enrollment application fee where applicable. Institutional providers, DMEPOS suppliers, opioid treatment programs (OTPs), and other applicable organizations should budget for the $750 application fee when enrolling, re-enrolling, revalidating, or adding a new practice location.
• Notify CMS of Medicare enrollment changes within CMS specified time periods. Changes in ownership or practice location, and final adverse legal actions, must be reported within the 30 days or 90 days reporting periods, as applicable, based on the type of change and provider category. 
• Individualize monitoring of each provider’s Medicare revalidation status. Do not use the standard revalidation cycle, instead, review the CMS Medicare Revalidation List and promptly respond to revalidation requests from your Medicare Administrative Contractor (MAC). 

Following this checklist can help providers, credentialing specialists, and medical billing teams reduce compliance risks, prevent avoidable enrollment delays, and maintain uninterrupted Medicare billing privileges.

Why Healthcare Organizations Trust CureCloudMD for CMS-Compliant Credentialing & Revenue Cycle Success?

Successful medical billing starts long before the first claim is submitted. At CureCloudMD, our credentialing specialists continuously monitor CMS regulations, Medicare enrollment requirements, PECOS updates, payer policies, and compliance standards to ensure every provider remains eligible to bill without unnecessary interruptions.

Our team of medical billing and coding manages the complete credentialing lifecycle, from Medicare enrollment and PECOS updates to revalidation, payer enrollment, provider onboarding, and ongoing compliance monitoring. Every enrollment record is carefully reviewed to help prevent documentation errors, enrollment delays, and credentialing issues that can lead to claim rejections or reimbursement delays.

We partner with healthcare organizations to help them: 

• Maintain CMS and payer compliance.
• Submit complete and accurate enrollment applications.
• Reduce enrollment-related claim delays and avoidable denials.
• Keep provider records updated across Medicare and commercial payers.
• Accelerate provider onboarding and billing readiness.
• Improve reimbursement timelines through proactive credentialing management.

With a dedicated team that stays current with evolving CMS policies and payer requirements, CureCloudMD helps providers protect their billing privileges, strengthen compliance, and build a more efficient revenue cycle from enrollment through reimbursement.

Contact us via email at [email protected] or call +1 205 947 3264 to start transforming your practice’s financial performance. Your revenue growth and financial peace of mind are our top priorities.